Renovator training

Calculating the amount of painted surface disturbed in the manner that the commenters suggested would also complicate the rule and be more difficult to convey during the renovator training course. In response to these comments, EPA has inserted clarifying language on this into the text of the definition of minor repair and maintenance activities at 40 CFR 745.83. 

Therefore, a significant portion of an abatement contractor s training is focused on abatement techniques and selection of the appropriate course of action for a variety of hazards. Renovators, on the other hand, do not seek to permanently eliminate lead hazards. Renovators perform maintenance and improvement tasks as directed by the consumer. The goal of EPA s renovator training and certification program is not to update the methodology a renovator uses to accomplish these tasks, with the exception of the practices prohibited or restricted by this final rule, but rather to introduce containment and cleaning methods to minimize exposure to lead-based paint hazards created by the renovation activity. 

It is important to note that OJT is not as portable as certified renovator training nor is it intended to be. Certified renovators... 

EPA does not believe that work experience requirements are necessary because previous experience in the construction or renovation industry would do litde to help an individual understand or perform the work practices, which are not standard practice in the industry. Consequently, there is no relevant work experience for EPA to require. In addition, the work practices required by this final rule are sufficiently straightforward that EPA does not believe it is necessary to require work experience in addition to certified renovator training. 

Under this final rule, individuals who successfully completed an accredited abatement worker or supervisor course, and individuals who successfully completed either HUD, EPA, or the joint EPA/HUD model renovation training courses may take an accredited refresher renovation training course in lieu of the initial renovation training to become a certified renovator. In addition, individuals who have successfully completed an... 

Commenters raised concerns and had suggestions regarding how certified renovator training should be conducted in three broad areas course length course content and format and training of non-English speaking renovators. 

One commenter asked about the availability of the cleaning verification card, specifically, who would produce them, where would they be available, and how often do they need to be replaced. EPA intends to produce the cleaning verification cards and to make them available at accredited renovator training courses and on request from the National Lead Information Center. Several commenters argued that a third party should perform cleaning verification (or visual inspection, in the case of exterior jobs) rather than the certified renovator. 

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